had been induced by the ministrations and words of the Protestant prison chaplain. The acknowledgment of the murder with which he was charged was made by the prisoner to the jailer and, subsequently, to the authorities. The Catholic Encyclopedia contends that he appears to have made no acknowledgment of his crime to the chaplain himself and that the question of confessional privilege did not arise. Broad v. Pitt In 1828, the case of Broad v. Pitt 3 C&P 518, where the privilege of communications to an attorney was under discussion, Best CJ said: R v. Shaw In R v. Shaw (1834) 6 C& P 392, a witness who had taken an oath not to reveal a statement which had been made to him by the prisoner, was ordered to reveal it. "Everybody", said Mr. Justice Patteson, who tried the case, "except counsel and attorneys, is compellable to reveal what they may have heard." Greenlaw v. King In the case of Greenlaw v. King (1838) 1 Beav 145, Henry Bickersteth, 1st Baron Langdale, Master of the Rolls said: R v. Griffin In R v. Griffin (1853) 6 Cox CC 219, a Church of England workhouse chaplain was called to prove conversations with a prisoner charged with child-murder whom, he stated, he had visited in a spiritual capacity. The judge, Baron of the Exchequer Sir Edward Hall Alderson, strongly intimated to counsel that he thought such conversations ought not to be given in evidence, saying that there was an analogy between the necessity for privilege in the case of an attorney to enable legal evidence to be given and that in the case of the clergyman to enable spiritual assistance to be given. He added, "I do not lay this down as an absolute rule: but I think such evidence ought not to be given". The Constance Kent Case In 1865, the murder trial of Constance Kent aroused a number of parliamentary questions whose answers reaffirmed the limited scope of professional privilege in England. R v. Hay In this 1860 case, a Catholic priest was committed for contempt of court for failing to give evidence as to how he came by an allegedly stolen watch on the grounds that it came into his possession by way of the confessional. The court insisted that he was asked a plain matter of fact and not to breach the seal of the confessional. The Catholic